United States: ISO 37001: Testing The Ability To Implement A Global Anti-Bribery Standard

A year after a global anti-bribery standard was implemented by
the International Standards Organization ("ISO"), a slow
trend is emerging among major corporations, such as Microsoft and
Wal-Mart, announcing they will seek certification under the
standard. This presents an opportunity for companies to obtain a
best practices certification concerning its anti-corruption
controls, which could serve as a favorable factor for lenience for
the corporation from criminal or civil enforcement authorities,
should a problem arise.

The ISO is an independent, non-governmental international
organization that aims to create international standards for
various industries including technology, food safety, agriculture
and healthcare. On October 14, 2016, the ISO adopted ISO 37001, a
global standard aimed at implementing an anti-bribery management
system designed to help prevent, detect and mitigate bribery. This
is a significant step towards solidifying a global a

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A provision in the False Claims Act ("FCA") had clarified when Anti-Kickback Statute ("AKS") violations can make a claim false, but the provision's rule of per se falsity does not answer when a claim "result[s] from" an AKS violation.